Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Recovery of excess tax paid which was not liable to be paid - tax payable on 'capital goods' 5% OR 14.5% - cheques issued under coercion - presumption that the petitioner has admitted his liability whereas as seen from the available records except for the issuance of cheques, there is no conclusive evidence to prove that the petitioner had admitted his liability - impugned notice quashed and the matter is remanded
Recovery of excess tax paid which was not liable to be paid - tax payable on 'capital goods' 5% OR 14.5% - cheques issued under coercion - presumption that the petitioner has admitted his liability whereas as seen from the available records except for the issuance of cheques, there is no conclusive evidence to prove that the petitioner had admitted his liability - impugned notice quashed and the matter is remanded
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